Law News

Over the past several years, the government has dramatically increased its efforts to enforce the Foreign Corrupt Practices Act. The number of enforcement actions brought annually by the Department of Justice and Securities and Exchange Commission, which both enforce the statute, has ballooned from an average of two to four in the first 20 years of the statute's existence to more than 30 in both 2007 and 2008. Officials have stated publicly that enforcement efforts will remain active for the foreseeable future, acknowledging that there are approximately 100 cases currently under investigation. With that in mind, it is worthwhile to look at the statute and some of the key trends that are likely to play a prominent role in 2009's enforcement environment.